## Vector Aerial Images, LLC **10301 Terry LN Portage, MI 49002** 

**FAA**
**- 2007** 
**- 0001** 

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

**Petition for Section 333**  **Exemption to Operate Unmanned Aircraft Systems for**  **Aerial Photography, Filming, Building and Tower Inspections**

Re:Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012 Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), United Services Automobile Association (USAA) is petitioning for an exemption from the Federal Aviation Regulations and other rules/statutes pertaining to unmanned aircraft sys tems. Section 333 of the FMRA addresses special rules for certain unmanned aircraft systems and grants the FAA authority to allow for the safe operation of certain unmanned aircraft systems (UAS) within the national airspace. Vector Aerial Images is here to provide the new technology of aerial filming and photography in the Southwest Michigan area. Our business will provide the Michigan area with the opportunity to give great aerial video and photography to the commercial business and community for the near future. Vector Aerial has already had the opportunity to shoot a few commercials and programs around the Kalamazoo area. Without this exemption we will not be able to serve the community with this great business. Our UAS systems consist of the Tarot 1000 and Tarot T18 which will serve many functions for the local
co mmunity. Vector Aerial Images will be using these UAS for building inspections, tower inspections, real estate photography and advertisement , local filming for commercials and small local events , in edition we will also be communicating with the local Portage Police and Fire Department and offering volunteer assistance should they need our services. This UAV will not only serve the local business purposes but also the local law enforcement and other community needs. In operating the Tarot 1000 and Tarot T18 , safety will be my number one priority during all operations and events. Both the Tarot 1000 an Tarot T18 are very safe UAS vehicles and have been proven in thefield with many other UAS devi ces known to be in service. Both UAS platforms are a heavy lift aerial

vehicle with all carbon fiber parts and 3 f ixed landing gear. The Tarot T18 is similar but has the foldable arms for transportation and storage. I chose the Tarot 1000 UAS because of th e fixed gear in the event that I should need to land quickly the gear are stationary in the down and locked position at all times and believe this is an important safety feature . This UAS consist of eight Sunnysky 340 KV motors which offer more than enough powers to safe altitudes and can be done quickly if needed. Sunnysky motors are known for their excellent qualities and safe operation. They have given me no problems/failures with more than 50 hours of operation

. This UAV offers more than a 1000’ fpm rate of climb easily and only weighs a total of 18 lbs when fully loaded with a Canon 5D DLSR. The eight motors also offer enough power should one motor fail during flight. I have tested this theo ry by flying with seven motors and the Ironman performed very well for the payload that I will be using. This UAS is equipped with the latest technology from 3D Robotics and uses the Pixhawk flight controller. This flight controller is equipped with the entire standard features such as altimeter, magnetic com pass, and gyros, but also with satellite GPS and sonar for close proximity to the ground. The functions available are stabilize mode which will be used at all times, GPS hold, altitude hold, and a return to home function which will always be used should
any radio interference happen. Also, a battery safety mode will be used should the batteries get under a pre - de scribed voltage. In any of these events, the Tarot 1000 will fly home to the predetermined take off point and land itself if needed using GPS and s onar and will do so if any signal is lost or any battery is below a preset voltage. Operating procedures will follow guidelines that I am used to in my Part 121 Airline experience and I will treat it as such. Operations with the Tarot 1000 will not be cond ucted during night, as defined in 14 CFR § 1.1 or in wet moisture such as heavy fog or any light rain. Operations will not continue if such weather develops. The procedures will begin with logging every part of my flight time and maintenance in a log book . The logbooks will consist of two separate logbooks from Jeppesen , one for maintenance and the other for flight time. Each logbook will have a section for the date, place, time of takeoff, time off landing, total flight time. Also the maintenance logbook will have the type of maintenance performed or any corrective actions taken to fix the discrepancy. In accordance with (14 CFR § 91.7(b)), e ach flight will begin with a “walk around” for a prefl ight safety checklist. I will have and create a physical paper checklist that will be followed for each flight that I can refer back to when needed. This will ensure that I will not miss any parts of the safety check before the flight. A fter landing there will also be a post flight safety check in
making sure all required items are still functional, attached, and working in a safe manner. Wire connections will be attached with heat shrink and electrical tape to prevent open circuits and loosened wires/conne ctions due to any chaffing or vibrations. Beyond the preflight and post flight checklist that will be used, I will have weekly inspection interval that will be used. This will be done with a flashlight to observe any parts of the UAS that are not in good lighting and not with in plain eyesight . I will be looking for any loose or worn wires, nuts, bolts, burn marks or anything that could be missed that is not in my regular pre/post flight checklist. Yearly routine maintenance will be performed . This will si milar to a C check done on a part 121 aircraft although not quite as extensive. Motors will be replaced if needed when showing where and tare. All bearing on the motors will be replaced along with bearings in parts of the hinges for the camera gimble and a ny boltsthat have wear will also be replaced. The UAS will be partly disassembled and checked for any abnormal

ware such as cracks or broken/loose parts. They will be replaced

. In accordance with the statutory mandate under Section 333(b)(1) the operation al borders that I will be operating in will always be in visual line of sight (VLOS) for the UAS. I will also have a camera equipment operator operating the camera on the UAS. They will be with me at all times and will also be observing the UAS. We both have clear concise information given before the flight. We talk about any obstacle s and anything or anyone that may be of concern to the safety of the flight including people and additional observers. We are well aware of the people who may like to watch and we will also mention to others to keep their distance while we are using the UAS. We will also have signs in the future near our operation that will tell others to stay back from the UAS and to not talk to the PIC UAS operator during operation until the UAS has landed and shutdown with motors off . This is very important to not create undo distraction to the PIC. Communication between myself (PIC) and the observer will be made from Takeoff to touchdown. I have invested in Motorola voice operated radio (vox) systems with an ear piece and microphone. Naturally these are hands free and we will be using them at all times even when we are within earshot off each other. This will keep us in clear communication at all times. To remain safe from the public, The UAS will remain a far distance from the general public and will not over fly anyone not involved in the operation and not in the explicit agreement of the operation of the UAS . We realize this and will be subject to strictly maintaining a safe distance from th e general public. I am requesting an exemption from 14 CFR § 91.119 but never to come within a 200’ proximity from the general public or anyone not involved in the agreement of UAS operation. T he UAS will maintain a distance of 200’ or greater from those persons . In addition, to not fly directly over any such person during the UAS operation. Some operations may require us to operate the UAS with in 500’ of any person not involved and not in direct agreement with the UAS operation . Th ese operations include inspections for certain city and municipal buildings and site s , over certain areas for police and fire departments such as aerial accident sites including areas for insurance claims of vehicles and buildings within the city limits

. I have obtained a radio operators license since I am a commercial airline pilot and all frequencies and equipment will be in compliance with the FCC. I am using the standard radio Frequency of 2.4 GHZ . As I am the sole owner of Vector Aerial Images, LLC and will be the sole PIC (Pilot in Command) of the aerial UAS for the Tarot 1000 and Tarot T18. My qualifications in the aviation industry include: **Airline Transport Pilot Airplane Multiengine Land** CL

- 65 Type rating, DHC

- 8 Type rating SIC Privileges 8400 Total Time 8000 Turbine 4800 PI C 8100 Multiengine 1000 Instrument 384 Single Engine **Certified Flight Instructor Instrument, Ground Instructor Restricted Radio Telephone Operator Permit**  **First Class Medical** I (PIC) meet the flight review requirements spe cified in 14 CFR § 61.56, and flight hours and currency are logged in a manner consistent with 14 CFR § 61.51(b).My qualifications in flying RC models airplanes extends to over 30 years of experience from flying gas

and electric aircraft and off road buggies. The last 5 years I have been flying helicopter s with the last 2 years of that including RC quad copters. I have been flying the Tarot 1000 and Tarot T18 for 1 year with no accidents or incidents. I have held a first class medical for over 12 years. Be fore that time I held a 3 rd class medical since 1990. \ The proposed maximum operating speed and limited airspeed for the UAS will be no faster than 50 MPH. We know from experience that the stopping distance is close to 18 ’ at high rate of speeds close to 40 MPH beginning from full forward pitch of 30 deg. , reaching full speed then to a full aft pitch deflection of 30 deg. and we have tested this. Being a good PIC involves knowing your UAS vehicles limitations and we have tested turning radius, start

- stop distances, climb rates, descent rates, and other limitations. We are very pleased with the performance of this UAS. Because of the nature of our business in performing smooth operational camera shots we will not be operating anywhere close to the abilities of the Tarot 1000 UAS but it always good to know of those abilities when we may need them. Staying out of clouds is of the utmost importance and would negate the VLOS rule. We will maintain at least 2000’ horizontally and 500’ below the clouds at all times keeping with the VFR distance requirements. At all times the UAS operation will never exceed 400’ and, in fact, will be much less than that within 5 miles or closer to any airport and subject to the airport managers approval and notification when appropriate. The majority of flight altitude’s (90%) will be with in 10

- 50’ AGL. Only occasional higher altitudes will be needed when surveying buildings, police or fire department issues. The operations involved for our UAS do not require us to operate within close proximity of an airport or outside of the United States. **Vector Aerial Images is requesting exemption for these items listed below: 14 CFR part 21, Certification procedures for products and parts, Subpart H** 

**— Airworthiness**  **Certificates 14 CFR**  **part 36 associated noise certification and testing requirements 91.103(b)(2) Preflight action**  **91.105 Flight crewmembers at stations 91.109 Flight instruction**  **91.119 Minimum safe altitudes 91.121 Altimeter settings**  **91.151 Fuel requirements for flights in VFR conditions**  **91.405 Maintenance required 91.407 Operation after maintenance**  **91.409 Inspections 91.417 Maintenance records8 Rev. 9/25/2014** 

I would to sincerely thank you for your time in this matter. Sincerely, Patrick Gage Vector Aerial Images 269

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